Justia Florida Supreme Court Opinion Summaries

Articles Posted in Florida Supreme Court
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Petitioner, convicted of first-degree murder of a state correctional officer, appealed an order of the circuit court denying his motion to vacate his death sentence under Florida Rule of Criminal Procedure 3.851 and petitioned for a writ of habeas corpus. The court rejected petitioner's claim of ineffective assistance of trial counsel, concluding that it was reasonable for trial counsel to not challenge the intended sexual battery evidence on undue prejudice grounds and the court's confidence in the trial court's conclusion was not undermined by the possibility of additional evidence about the effect of petitioner's childhood on his mental status. The court also concluded that, because petitioner's challenges to Florida's death penalty scheme were meritless, appellate counsel did not err by failing to raise the arguments on direct appeal and petitioner was not entitled to habeas relief. Accordingly, the court affirmed the denial of postconviction relief and denied the petition for a writ of habeas corpus. View "Smith v. State" on Justia Law

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Defendant appealed his conviction for first-degree murder and sentenced of death. On appeal, defendant raised eighteen claims of error and the State raised a claim regarding the proportionality of the death sentence in this case. The court concluded that defendant's claims were without merit, with the exception of Issue 2 regarding the scope of cross-examination. However, the court concluded that this error was harmless. The court also concluded that the death sentence was proportionally warranted in this case. Accordingly, the court affirmed the conviction and sentence. View "Gosciminski v. State" on Justia Law

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Plaintiffs sued defendant, seeking recovery for injuries allegedly sustained in an automobile collision. This case concerned the proper standard of review and the appropriate remedy when an appellate court reviewed a trial court's order granting a new trial on the ground that the jury verdict was contrary to the manifest weight of the evidence, where the trial court's order was premised, at least in part, on an error of law. The court held that an appellate court properly applied a de novo standard of review to a trial court's conclusions of law in an order granting a new trial based on the manifest weight of the evidence, giving no deference to the trial court's legal conclusions. Although a trial court's conclusions of law were not entitled to deference, its findings of facts and determinations of credibility were still entitled to deference because of the trial court's superior vantage point of having been present during the entire trial. Although the court concluded that the First District was correct in reversing the trial court's order, the court quashed the First District's decision because it concluded that reinstatement of the jury verdict was not the proper remedy in this case. Accordingly, the court remanded for reconsideration. View "Van, Sr., et ux., v. Schmidt" on Justia Law

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Defendant was charged with burglary, grand theft, dealing in stolen property, and providing false information to a pawnbroker. The trial court refused to refer to Fla. Stat. 812.025 in its jury instructions or otherwise instruct the jury that it was precluded from finding Defendant guilty of both dealing in stolen property and theft. Defendant was convicted of all of the charges, but the trial judge subsequently dismissed the grand theft conviction. Defendant appealed, arguing that he was entitled to a new trial because the trial court denied his requested instruction modeled on section 812.025. The court of appeal affirmed. The Supreme Court quashed the decision of the court of appeal, holding (1) a trial court must instruct the jury pursuant to section 812.025 when both theft and dealing in stolen property offenses are submitted to the jury; (2) if a trial court denies a defendant's request for a jury instruction under section 812.025, the defendant must be given a new trial if the jury convicts the defendant of both theft and dealing in stolen property; and (3) Defendant was entitled to a new trial on the dealing in stolen property and grand theft counts. View "Williams v. State" on Justia Law

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Defendant was charged with burglary, petit theft, and dealing in stolen property. The trial court did not instruct the jury it could not return a guilty verdict for both theft and dealing in stolen property pursuant to Fla. Stat. 812.025, and Defendant did not request such an instruction. The jury found Defendant guilty of both offenses. Defendant appealed, asserting that he was entitled to a new trial because he was convicted of both petit theft and dealing in stolen property in violation of section 812.025. The district court concluded that although Defendant did not object to the dual convictions at trial, he was permitted to challenge the convictions on appeal. The court then vacated the petit theft conviction. The Supreme Court affirmed, holding (1) although the trial court erred in rendering the dual convictions, it was not fundamental error such that would require a new trial; and (2) accordingly, the district court properly affirmed Defendant's dealing in stolen property conviction while reversing his petit theft conviction. View "Blackmon v. State" on Justia Law

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On May 13, 2013, the Governor signed a death warrant for Defendant and set the execution date. After Defendant's state counsel wrote the Governor a letter stating there was reason to believe Defendant was insane to be executed, a group of psychiatrists conducted an examination of Defendant and concluded that Defendant was sane to be executed. Defendant's federal counsel subsequently filed a motion for stay and hearing, challenging Defendant's competency to be executed. After an evidentiary hearing, the circuit court found Defendant sane to be executed and lifted its stay. The Supreme Court affirmed, holding that competent, substantial evidence supported the circuit court's determination that Defendant was sane to be executed. View "Gore v. State" on Justia Law

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In 2003, Petitioner was convicted of committing various offenses and was sentenced to terms of imprisonment. Petitioner subsequently filed numerous nonmeritorious pleadings and requests for relief related to his criminal convictions. Petitioner's petitions in the instant cases were denied as procedurally barred in 2012, and Petitioner was ordered to show cause why he should not be barred from filing in the Court any future pro se pleadings or requests for relief pertaining to his criminal convictions. After Petitioner failed to file a response, the Supreme Court barred Petitioner from any future pro se filings related to his criminal convictions and concluded that Petitioner's petitions in these cases were frivolous proceedings initiated by a prisoner. View "Werdell v. Crews" on Justia Law

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Lakeview Reserve Homeowners Association filed an action against Maronda Homes for breach of the implied warranties of fitness and merchantability, also referred to as the implied warranty of habitability in the residential construction context. The underlying cause of action arose from alleged defects in the construction and development of a residential subdivision that Maronda Homes and T.D. Thomson Construction Company developed. Lakeview Reserve served as the homeonwers association of the division. Maronda Homes filed a third-party complaint against T.D. Thomson for indemnification based on the alleged violations by Maronda Homes. The trial court entered summary judgment in favor of Maronda Homes and T.D. Thompson, finding that the common law implied warranties of fitness and merchantability do not extend to the construction and design of the private roadways, infrastructure, or any other common areas in a residential subdivision. The court of appeal reversed, holding that the common law warranty of habitability applied in this case. The Supreme Court affirmed, holding that the implied warranties of fitness and merchantability applied to the improvements that provided essential services to the homeowners association. Remanded. View "Maronda Homes, Inc. of Fla. v. Lakeview Reserve Homeowners Ass'n" on Justia Law

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Among other crimes, Defendant pleaded guilty to the first-degree murder of Michelle Simms and was sentenced to death. The Supreme Court vacated the death sentence and remanded. After the second sentencing proceeding, the trial judge imposed the death sentence for the first-degree murder. Defendant subsequently filed a postconviction motion, raising claims of ineffective assistance of counsel. The circuit court denied relief on all claims. The Supreme Court affirmed the trial court's denial of Defendant's postconviction motion, holding that the circuit court (1) did not err in denying Defendant's claim of ineffective assistance of defense counsel regarding Defendant's guilty plea; and (2) did not err in summarily denying Defendant's claim of ineffective assistance of counsel for failure to object to prosecutorial misconduct during the penalty phase. View "Long v. State" on Justia Law

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Defendant pled nolo contendere to a misdemeanor driving with a suspended license charge in violation of Fla. Stat. 322.34(2) and was sentenced to a term of probation. On the same day, the state attorney filed an information charging Defendant with a violation of the felony unlawful driving as a habitual traffic offender statute, Fla. Stat. 322.34(5). Defendant filed a motion to dismiss the information, arguing that it violated Florida's prohibition against double jeopardy. The circuit court granted Defendant's motion to dismiss the felony information. The court of appeal reversed. The Supreme Court quashed the decision of the court of appeal and concluded that the trial court properly granted the motion to dismiss the felony information, holding that dual prosecutions under (2) and (5) of section 322.34 are both statutorily and constitutionally prohibited. View "Gil v. State" on Justia Law